Allied-Signal, Inc. v. Director, Div. of Taxation, 504 U.S. 768, 28 (1992)

Cite as: 504 U. S. 768 (1992)

O'Connor, J., dissenting

at 175. Because petitioner has failed to show by clear and cogent evidence that the income derived from the ASARCO investment was not related to the operations of its unitary aerospace business, part of which was in New Jersey, New Jersey should be able to apportion and tax that income. As the Court holds that it may not, I must respectfully dissent.